Traders or their advisers if they have one, are responsible for interpreting the law and applying it to their circumstances. Difficulties of interpretation create uncertainty and provide scope for error and for arriving at conclusions which are later challenged by HMRC.

Certainty is important for business because commercial decisions are taken as regards matters such as price, for which the VAT treatment of supplies and the right to recover underlying input tax are often significant factors in the equation. In practice, some such decisions must be made in less than ideal circumstances.

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